Opinion
37893-21S
07-28-2022
HENRY H. ARNOLD & PAULINE R. ARNOLD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On July 21, 2022, the Court received from the parties in the above-docketed matter a Proposed Stipulated Decision resolving this litigation. That decision was premised on a Settlement Stipulation filed the same date establishing an overpayment for the underlying 2018 taxable year. However, review shows that the Proposed Stipulated Decision appears to reflect an increased deficiency that has never been appropriately pled or otherwise expressly stipulated by the parties. The Court would expect a stipulation to that effect to be included below the intended judicial signature. Merely showing the larger amount on a Statement of Account is insufficient.
The premises considered, and for cause, it is
ORDERED that the Proposed Stipulated Decision and Settlement Stipulation, both filed July 21, 2022, are hereby deemed stricken from the Court's record in this case.